People vs. Trilles

G.R. No. 114388 (March 12, 1996)

Facts:

On January 5, 1991, at approximately 3:30 PM, in Barangay San Jose, Oas, Albay, the accused—Domingo Trilles, Silvestre Trilles, Igmidio Bibliaas, and Epitacio Riofrir, Jr.—were charged with the crime of Robbery with Homicide. The prosecution's case centered around the events leading to the death of Vicente Rellama, who was attacked in his home during a robbery.

The incident began when Maximina Rellama Balde, the victim's daughter and barangay captain, sent her brother-in-law, Leopoldo Balde, to Vicente's house for an errand. While Vicente was at home, he was visited by the accused, who demanded money. When Vicente claimed he had none, Domingo Trilles attacked him with a bolo, inflicting multiple hack wounds. The other accused joined in the assault, leading to Vicente's death. Witnesses Felix Repia and Leopoldo Balde observed the attack and later reported it to local authorities.

The prosecution presented evidence, including a necropsy report indicating that Vicente sustained ten hack wounds, which led to his death from internal and external hemorrhage. The accused, however, pleaded not guilty and presented alibis claiming they were elsewhere at the time of the crime.

Legal Issues:

1. Whether the trial court erred in giving weight to the testimonies of the prosecution witnesses.
2. Whether the evidence presented by the prosecution was sufficient to establish the guilt of the accused beyond a reasonable doubt.

Arguments:

Prosecution:

• The prosecution argued that the testimonies of eyewitnesses Felix Repia and Leopoldo Balde were credible and consistent. They identified the accused as the perpetrators of the crime and provided detailed accounts of the events leading to Vicente's death.
• The prosecution maintained that the alibis presented by the accused were weak and did not establish their physical impossibility to be at the crime scene.

Defense:

• The defense contended that the trial court erred in relying on the inconsistent testimonies of the prosecution witnesses. They pointed out discrepancies in the accounts of Felix and Leopoldo regarding whom they reported the incident to and the specifics of what they witnessed.
• The defense also argued that the alibis of the accused were credible and corroborated by other witnesses, asserting that they were not present at the scene of the crime.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding the accused guilty of Robbery with Homicide. The court reasoned that the eyewitnesses provided positive identification of the accused, which was corroborated by the circumstances surrounding the crime. The court dismissed the defense's claims of inconsistencies as trivial and noted that the eyewitnesses had no motive to falsely implicate the accused.

The court also found that the alibis presented by the accused were insufficient to create reasonable doubt. The proximity of the accused to the crime scene undermined their claims of being elsewhere. The court emphasized that the prosecution's evidence, including the eyewitness accounts and the necropsy report, established the elements of the crime beyond a reasonable doubt.

Significant Legal Principles:

• The case underscores the importance of eyewitness testimony in establishing the identity of the perpetrators in criminal cases.
• It highlights that alibi defenses must demonstrate physical impossibility to be effective, particularly when the accused are in close proximity to the crime scene.
• The court's ruling also reflects the principle that minor inconsistencies in witness testimonies do not necessarily undermine their credibility if the core of their accounts remains consistent and reliable.